Acordis Industrial Fibers Inc. - Executive Summary |
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Accidental release prevention and emergency response policies: Acordis Industrial Fibers Inc. is committed toward fulfilling the environmental protection needs of the surrounding community, and its employees and customers, by maintaining an environmental management system that adheres to all federal, state and local laws applicable to the facility. Acordis strives for continuous improvement of environmental protection, pollution prevention and protection of natural resources through the establishment of environmental targets, objectives and reviews. Environmental aspects that impact the air, water and land are monitored and evaluated. Employee awareness of environmental impacts is promoted through on-site training. In the event of an emergency, it is Acordis' policy to notify the Scottsboro Fire Department Hazardous Materials Team and the Jackson County Local Emergency Planning Committee (LEPC) for response. The expertise of these agencies and their familiarity with the chemicals stored at this facility help to ensure proper and prompt handling of any emergency situation that may arise. Facility description and regulated substances handled: The Acordis Industrial Fibers Inc. facility manufactures industrial polyester yarn, polyester tire cord fabric, and nylon yarn for automotive air bags. A melt spinning process technology is utilized to create fibers that can be twisted or woven into industrial yarns and fabrics. A latex coating is applied to a portion of the polyester fibers to produce tire cord fabric. This coating gives the fabric adhesive properties, allowing it to form a strong bond with rubber tire components, and in turn allows our customers to build a longer wearing automotive tire. Formalin, a 35% formaldehyde-water solution, is one of the ingredients used in this latex coating. Acordis stores the formalin in an 11,280-gallon storage tank surrounded by a secondary containment dike capable of holding the entire contents of the tank. A contain ed truck unloading area used to receive formalin shipments, along with associated piping, pumps, valves and other miscellaneous equipment help to ensure a safe and environmentally sound transfer of formalin for processing. The worst-case release scenario: Hypothetically, the worst-case release scenario would be failure of the 11,280-gallon formalin storage tank when filled to capacity, resulting in a spill of its entire contents into a secondary containment dike and evaporation of the liquid. The secondary containment dike is capable of holding the entire contents of the tank, which would minimize the liquid surface area, and thus the evaporation rate, in the event of a worst-case release scenario. Tank failures most often occur due to overpressure or corrosion of the tank shell. At this facility, formalin is not stored under pressure, and the tank, and associated piping, pumps, valves and other miscellaneous equipment are periodically inspected for corrosion. Therefore, a wors t-case scenario is highly improbable. According to EPA's look-up tables in the RMP Offsite Consequence Analysis Guidance document, the distance from the tank to the toxic endpoint, a point at which the air quality would be considered safe, is 0.19 miles (1003 feet). This analysis was based on the rural model due to the fact that the facility is located in a relatively open area with few obstructions (e.g., buildings, etc.). Since the storage area is located near the center of the facility's extensive property, a worst-case release scenario would not affect anyone beyond the property boundaries. Furthermore, the EPA's look-up tables are based on a 37% formaldehyde-water solution; the solution used at this facility is only 35%, which technically would result in a lesser distance to the toxic endpoint in the unlikely event of a worst-case release scenario. The general accidental release prevention program and chemical-specific prevention steps: This facility complies with EPA's acci dent prevention rule and all applicable state and local codes and regulations. The formalin storage process was designed and installed according to accepted industry codes and guidelines. On-going training and preventative maintenance, periodic inspections, and the conformance to operating procedures help to minimize the likelihood of any release from this process. Five-year accident history: This facility has never had an accident involving formaldehyde that caused deaths, injuries, property or environmental damage, evacuations, or shelterings in place. The emergency response program: In the event of an emergency involving our formalin storage process, it is Acordis' policy to notify the Scottsboro Fire Department Hazardous Materials Team and the Jackson County LEPC and request that they respond to the emergency. This policy has been discussed and coordinated with the LEPC. Additionally, Acordis is included in the LEPC's Jackson County Emergency Operational Plan. Planned chan ges to improve safety: Continuous improvement of the facility's safety program is an ongoing effort. There are no planned changes to improve safety pertaining to the formalin storage process at this time. However, management proactively considers suggestions from its employees, stays abreast of safety and technological advances associated with all of its equipment and processes, and incorporates safeguards that are necessary to help ensure protection of the surrounding community and its employees. |